# 05 20 Viaduct Harbour Avenue, Auckland 1010 Private Bag 92250, Auckland 1142, New Zealand Phone 09 355 3553 Website www.AT.govt.nz 10 August 2021 Attention: Planning Technician Auckland Council Level 24, 135 Albert Street Private Bag 92300 Auckland 1142 Email: [email protected] Dear Sir / Madam NOTICE OF REQUIREMENT BY CITY RAIL LINK LIMITED FOR ALTERATION OF BRITOMART TRANSPORT CENTRE DESIGNATION 2501 Please find attached Auckland Transport’s submission on the above Notice of Requirement by City Rail Link Limited. If you have any queries in relation to this submission, please contact Teresa George on 09 448 7275 or [email protected]. Teresa George Senior Planner, Land Use Policy and Planning (Central) Encl: Auckland Transport’s submission on Notice of Requirement for the alteration to the existing Britomart Transport Centre Designation 2501 Cc: City Rail Link Limited PO Box 9681 Newmarket Auckland 1149 Attention: Richard Jenkins, CRL Principal Planner Email: [email protected] 1 of 19 # 05 SUBMISSION BY AUCKLAND TRANSPORT ON A NOTICE OF REQUIREMENT BY CITY RAIL LINK LIMITED FOR ALTERATION OF BRITOMART TRANSPORT CENTRE DESIGNATION 2501 To: Auckland Council – Plans and Places Private Bag 923000 Auckland 1142 Submission on: Alteration to Designation 2501 Britomart Transport Centre by City Rail Link Limited to enable the retention of the Station Plaza Accommodation at Britomart so the building and surrounding Station Plaza area can be used as a construction support facility for works in the City Rail Link tunnels located within the adjoining designation, with the identification of the construction support activity components. From: Auckland Transport – Planning and Investment Private Bag 92250 Auckland 1142 Introduction: Auckland Transport is a Council Controlled Organisation (CCO) of Auckland Council with the legislated purpose to contribute to an “effective, efficient and safe Auckland land transport system in the public interest”.1 In fulfilling this role, Auckland Transport is responsible for: a. The planning and funding of public transport; b. Promoting alternative modes of transport (i.e. alternatives to the private motor vehicle); c. Operating the local roading network; and d. Developing and enhancing the local road, public transport, walking and cycling networks. Auckland Transport could not gain an advantage in trade competition through this submission. Auckland Transport’s submission is: Auckland Transport supports the Notice of Requirement, subject to the matters raised in Attachment 1 being addressed to ensure that any adverse effects on the operation of the transport network are avoided, remedied or mitigated. Auckland Transport wants to ensure that the temporary construction related effects on the ongoing operation of the transport network are appropriately mitigated, including through the inclusion of conditions that deal with the following: ‐ The requirements and mitigation of the potential construction related effects associated with the scope of the alteration ‐ Routing of construction vehicle and truck movements ‐ Manoeuvring of construction vehicle and truck movements to and from the construction site 1 Local Government (Auckland Council) Act 2009, section 39 2 2 of 19 # 05 ‐ Access to existing properties ‐ Managing cumulative temporary construction related effects ‐ Monitoring of construction effects. This submission acknowledges the requirement for the applicant to seek Auckland Transport’s s177(1)(a) approval to alter Auckland Transport’s Designation 1556 as the underlying designation to City Rail Link Limited’s (CRLL) 2501 Designation. The matters of concern that are outlined in Attachment 1 will also need to have been addressed by CRLL before section s177(1)(a) approval is given by Auckland Transport. The specific parts of the Notice of Requirement that this submission relates to and reasons for Auckland Transport’s views are outlined in Attachment 1. Auckland Transport seeks resolution of the various matters raised in this submission which, for example, could include amended conditions, additional conditions, and/or methods to ensure any effects on the transport network are managed in support of the proposal. Auckland Transport is available and willing to work through the matters raised in this submission with the applicant. Recommendations sought: The recommendations that Auckland Transport seeks from the Council are set out in Attachment 1. In all cases where amendments to the Notice of Requirement are proposed, Auckland Transport would consider alternative wording or amendments which address the reasons for Auckland Transport's submission. Auckland Transport also seeks any consequential amendments required to give effect to the recommendations sought. Appearance at the hearing: Auckland Transport wishes to be heard in support of this submission. If others make a similar submission, we will consider presenting a joint case with them at a hearing. ______________________ Signed for and on behalf of Auckland Transport Christina Robertson Group Manager, Strategic Land Use and Spatial Management Date: 10 August 2021 3 3 of 19 # 05 Address for service: Teresa George Auckland Transport Private Bag 92250 Auckland 1142 Telephone: +64 9448 7275 Email: [email protected] 4 4 of 19 # 05 Attachment 1 Issue Position Reasons Recommendation sought from the Council General overview Support, City Rail Link Limited is seeking a Notice of Requirement (NOR) Agreement with the subject to to alter their existing Designation 2501 – Britomart Transport proposal to alter the existing concerns Centre. designation, subject to any being further or other relief, or addressed The NOR provides for an alteration to the existing designation to other consequential or other enable the retention of the Station Plaza Accommodation building amendments considered at Britomart, so that the building and surrounding Station Plaza appropriate and necessary area can be used as a construction support facility for works in to address the concerns the City Rail Link tunnels located within the adjoining designation. identified in this submission. Auckland Transport supports and recognises the need for the works associated with the NOR to facilitate the construction of the City Rail Link (CRL) project. When completed, the CRL will support the wider growth of the region by enabling improved public transport network connections, frequency and capacity. Given that the works associated with the construction of the CRL requires construction to take place within the existing City Centre environment, the need to co-ordinate and safeguard the operation and on-going provision of other infrastructure is unavoidable, including access to and the operation of existing transport infrastructure and facilities. Auckland Transport seeks resolution of the various matters raised in this submission which, for example, could include conditions and/or methods to ensure any effects on the transport network are managed in support of the proposal. These matters may broadly relate to a range of concerns or issues including but not limited to construction management, maintaining the operation of public transport facilities, ensuring pedestrian accessibility and safety, vehicle access and safety. 5 5 of 19 # 05 Issue Position Reasons Recommendation sought from the Council Section 177(1)(a) Support in Auckland Transport’s Designation 1556 for the construction, That before Auckland approval part operation and maintenance of a transport centre and the provision Transport’s approval is of a rail system is the underlying designation to City Rail Link given under s177(1)(a), the Limited’s (CRLL) 2501 Designation. concerns outlined in this submission will need to have As the Requiring Authority for Designation 1556, Auckland been addressed by CRLL. Transport is responsible for ensuring that the on-going operation of the Britomart Station is not hindered or prevented. This includes the safe and convenient pedestrian access to and from the station. Auckland Transport notes that the matters of concern that it has outlined in this submission will also need to be addressed by CRLL before section 177(1)(a) approval is given by Auckland Transport. The Assessment of Environmental Effects (AEE) indicates that section 177(1)(a) approval under the RMA will be sought from Auckland Transport2 and it is understood that this approval had not been sought at time this submission was made. Effects on the Support in The applicant’s AEE indicates that construction traffic related To amend Designation 2501 transport network part effects would be less than minor, with this being premised on conditions by including an (temporary network applying a Construction Traffic Management Plan (CTMP). additional condition setting operations) – out the objectives and key designation condition The applicant has provided an Integrated Transport Assessment requirements of the (ITA)3 report to support the proposed NOR. Auckland Transport Construction Traffic broadly agrees with the approach of applying a CTMP to manage Management Plan (CTMP) temporary effects on the surrounding transport network. It is noted as they relate to “The Works” associated with the NOR alteration. 2 Assessment of Effects on the Environment, Britomart Transport Centre Notice of Requirement Alteration to Designation 2501, June 2021, Table 3‐2. 3 Assessment of Effects on the Environment, Britomart Transport Centre Notice of Requirement Alteration to Designation 2501, Appendix C City Rail